Under the regulations practitioners are required to risk-profile their business
Section 4 of the CCAB anti-money laundering guidance for the accountancy sector highlights that businesses are required to analyse the money laundering or terrorist financing (MLTF) risks they face and make proportionate responses to them. It also requires those who supervise to assess the risk analysis the business has undertaken.
It is important to remember that the guidance is built on a proportionate risk-based approach. As the guidance states, the ‘risk-based approach requires evidence-based decision-making to better target risks. No procedure will ever detect and prevent all MLTF, but a realistic analysis of actual risks enables a business to concentrate the greatest resources on the greatest threats.’
A sole practitioner undertaking accounts preparation work with locally based clients whom they meet face to face will have a different risk profile and policy from a large firm undertaking international tax work, holding client monies within client accounts and not meeting clients face to face.
ACCA produces a range of policy and procedures documents that members can adapt.
You can also find other examples in ACCA’s engagement letters.